Effective communication is an essential part of healthcare. More informed consumers are better prepared to discuss issues with their doctors and make healthier choices. From public health agencies and providers to pharma marketers, many groups need to engage and educate patients.

However, to communicate effectively—and, ultimately, improve health outcomes—marketers need to earn the trust of consumers. Modern advances in data and technology allow marketers today to better understand their customers and target relevant messaging based on their online (and offline) behavior. But just because certain targeting techniques are possible, does not mean they should be done. Self-regulatory guidelines help marketers know where to draw the line.

The NAI: What it Means for Marketers

All pharma marketers should be aware of the Network Advertising Initiative (NAI) and its Code of Conduct. The NAI is the leading self-regulatory association dedicated to responsible data collection and its use for digital advertising, with members including networks, exchanges, DMPs, SSPs, RTB platforms, analytics companies, and service providers. In May, the NAI revised their Code to help publishers and advertisers navigate the complex world of digital advertising. The new Code of Conduct goes into effect on January 1, 2020.

With the sensitive nature of health communications, the NAI code provides very specific guidelines for “Tailored Advertising” (aka targeted ads):

  • Tailored Advertising based on inferred interest in sensitive health conditions (i.e., oncology, sexual health, and mental health) requires opt-in consent. Inferred interest may include behavioral targeting or retargeting based on online behavior.
  • Tailored Advertising based on known medical conditions of individuals requires opt-in consent. This applies for both sensitive and non-sensitive conditions.

With these limitations on Tailored Advertising, how can marketers effectively reach health audiences? Enter data and analytics! With the right methodology in place, data and analytics can help you better understand health audiences and reach them in an efficient and privacy-safe way.

To start, you need access to large health and non-health datasets to learn which non-health data elements are relevant for a specific health condition. Consumer data can then be used to create an “enhanced demographic” propensity model to help find desired health consumers. Using analytics in this way enables health marketers to target audiences based on consumer information, not health information. This increases the likelihood that health messaging will reach a relevant audience, while preserving the privacy of individuals.

Targeting Practices to Avoid

Any successful targeting campaign starts with the right data—data that is sourced and used responsibly and is sensitive to the unique concerns of health consumers. Marketers should be aware of, and reject, any of these risky targeting approaches.

Audience segments containing individuals based on their actual healthcare data: The 2020 NAI Code of Conduct prohibits the use of an individual’s health data to target that individual. There are approaches in the marketplace that are in direct conflict with this provision of the Code, including segments that contain individuals based on their actual healthcare data (e.g., medical records), along with added unrelated individuals (also known as data “noise”). This approach assumes that by adding sufficient noise, the actual patients cannot be identified. Regardless of this attempt to anonymize the targeting, any use of an individual’s actual health data, even if for one person, violates the Code and an individual’s reasonable expectation of privacy around their healthcare data. Medical records are explicitly off limits for targeted advertising.

Actual healthcare data at the 9-digit zip code level (“ZIP+4”): Geo-targeting at the 9-digit zip code level (also known as ZIP+4) based on actual healthcare data is not sufficiently privacy-safe. In rural areas of the country, using ZIP+4 may target as few as three to four households. Certain conditions are closely associated with age and gender, increasing the risk of re-identification of individuals with specific health conditions. In other words, this approach may violate individuals’ reasonable expectation that their personal health data will not be used to target advertising to them.

Questions to Ask Your Agency

Marketers, advertising platforms, and publishers should follow responsible business and marketing practices with respect to the use of health data. Marketers should take a privacy-first approach when evaluating potential partners—considering:

  • Does the data used to target advertising include the actual health information of the patients targeted?
  • Are you using an approach with actual health data at the 9-digit zip code level?
  • Does your ad targeting for sensitive conditions infer an individual’s health interest, as with re-targeting or other behavioral approaches?

By rejecting questionable targeting approaches that may not adequately protect the privacy of consumers, healthcare marketers can help enforce a compliant and responsible advertising ecosystem. Using appropriate data and analytics protects the valuable, modern approaches that reach consumers in an efficient and privacy-safe way.

  • Sarah Caldwell

    Sarah Caldwell is General Manager, Crossix Analytics at Veeva. Sarah is responsible for Crossix measurement and optimization and audience targeting solutions at Veeva Systems. Crossix leverages connected health data to help life sciences more effectively activate, measure, and optimize their marketing investments. Sarah joined Crossix in 2007 and has consulted with pharmaceutical brands across various therapeutic areas and business situations, including launch and loss of exclusivity.


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